NEUCOM PRIVACY POLICY
NEUCOM TECH INC. CONDUCTING BUSINESS AS NEUCOM ("NEUCOM") VALUES AND RESPECTS THE PRIVACY OF ITS CLIENTS.
THIS PRIVACY POLICY INFORMS YOU OF NEUCOM'S PRIVACY PRACTICES REGARDING YOUR USE OF WWW.GETKASPER.COM (“KASPER”) OR THE KASPER MOBILE APP (“KASPER").1. SCOPE AND ACCOUNTABILITY
THIS PRIVACY POLICY GOVERNS THE COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION AND CLIENT INFORMATION (EACH AS DEFINED BELOW) IN CONNECTION WITH YOUR USE OF THE SITE. THIS PRIVACY POLICY DOES NOT APPLY TO INFORMATION THAT IS NOT INCLUDED IN THE DEFINITION OF "PERSONAL INFORMATION" IN APPLICABLE PRIVACY STATUTES.
ALL EMPLOYEES AND THOSE WORKING ON BEHALF OF NEUCOM ARE RESPONSIBLE FOR FOLLOWING THIS PRIVACY POLICY. NEUCOM ALSO HAS A PRIVACY OFFICER WHO IS RESPONSIBLE FOR OVERSEEING NEUCOM'S COMPLIANCE WITH THIS PRIVACY POLICY.
PLEASE SEE "CONTACTING US" FOR INFORMATION ON HOW TO CONTACT NEUCOM'S PRIVACY OFFICER.2. COLLECTION, USE AND DISCLOSURE OF CLIENT INFORMATION AND PERSONAL INFORMATION
COLLECTION
CLIENT INFORMATION MEANS ANY DATA, INCLUDING PERSONAL INFORMATION, RELATING TO ANY USER OF THE SITE THAT IS ENTERED ON THE SITE OR THAT IS STORED WITH NEUCOM OR THIRD PARTIES ENGAGED BY NEUCOM. PERSONAL INFORMATION MEANS ANY INFORMATION THAT MAY IDENTIFY A PERSON, SUCH AS A NAME, HOME ADDRESS, TELEPHONE NUMBER, DATE OF BIRTH, E-MAIL ADDRESS AND SOCIAL INSURANCE NUMBER/SOCIAL SECURITY NUMBER, AMONG OTHER THINGS.
WHEN YOU VISIT THE SITE, NEUCOM MAY COLLECT PERSONAL INFORMATION THAT YOU PROVIDE WHEN YOU:
REGISTER TO USE THE SITE; OR
CONTACT NEUCOM.
IN ORDER TO PROCESS LOAN APPLICATIONS THROUGH THE SITE, YOU WILL BE PROVIDING NEUCOM WITH CLIENT INFORMATION. TO THE EXTENT THAT YOU HAVE PROVIDED NEUCOM WITH CLIENT INFORMATION THAT WAS NOT COLLECTED BY YOU IN ACCORDANCE WITH THE FOREGOING, YOU AGREE TO INDEMNIFY NEUCOM FOR ANY CLAIMS OR POTENTIAL CLAIMS MADE AGAINST NEUCOM AND RELATING TO NEUCOM'S USE AND STORAGE OF SUCH CLIENT INFORMATION. SUCH INDEMNIFICATION BY YOU WILL EXTEND TO ALL LOSSES RELATING TO SUCH CLAIM THAT ARE INCURRED BY NEUCOM, INCLUDING EXPENSES.
NEUCOM MAY ALSO COLLECT PERSONAL INFORMATION DURING YOUR VISIT TO THE SITE THROUGH AUTOMATIC DATA COLLECTION TOOLS, WHICH INCLUDE WEB BEACONS, COOKIES, EMBEDDED WEB LINKS, AND OTHER COMMONLY USED INFORMATION-GATHERING TOOLS. THESE TOOLS COLLECT CERTAIN STANDARD INFORMATION THAT YOUR BROWSER SENDS TO ITS WEBSITE SUCH AS YOUR BROWSER TYPE AND LANGUAGE AND ACCESS TIMES. THEY MAY ALSO COLLECT INFORMATION ABOUT YOUR INTERNET PROTOCOL ADDRESS AND MAC ADDRESS.
NEUCOM MAY ALSO USE SOME OF THESE AUTOMATIC DATA COLLECTION TOOLS IN CONNECTION WITH CERTAIN E-MAILS SENT FROM NEUCOM AND THEREFORE MAY COLLECT INFORMATION USING THESE TOOLS WHEN YOU OPEN THE E-MAIL OR CLICK ON A LINK CONTAINED IN THE E-MAIL.
WE REQUEST A PHONE NUMBER AND EMAIL ADDRESS IN CASE ONE OF OUR REPRESENTATIVES WOULD NEED TO REACH YOU.
USES
IN ADDITION TO THE SPECIFIC PURPOSES DESCRIBED ABOVE, CERTAIN USES OF CLIENT INFORMATION BY NEUCOM MAY BE PERFORMED BY NEUCOM AFFILIATES, SERVICE PROVIDERS, AGENTS AND THIRD PARTIES AS DESCRIBED BELOW.
(1) NEUCOM'S USE OF CLIENT INFORMATION AND PERSONAL INFORMATION
NEUCOM SHALL ENSURE THAT THE USE AND DISCLOSURE OF CLIENT INFORMATION AND PERSONAL INFORMATION THAT IT RECEIVES FROM YOU IS LIMITED TO THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY, YOUR AGREEMENTS WITH NEUCOM, AND AS REQUIRED BY LAW.
NEUCOM MAY ALSO USE CLIENT INFORMATION AND PERSONAL INFORMATION TO:
IDENTIFY YOU WHEN YOU LOG IN TO YOUR ACCOUNT;
ENABLE US TO PROVIDE OUR SERVICES TO YOU;
VERIFY TRANSACTIONS YOU MAKE AND FOR BILLING, SECURITY, AND AUTHENTICATION;
ANALYZE THE SITE, OR THE OTHER SERVICES AND INFORMATION ABOUT OUR VISITORS, INCLUDING RESEARCH INTO OUR USER DEMOGRAPHICS AND USER BEHAVIOUR IN ORDER TO IMPROVE OUR CONTENT AND SERVICES;
AGGREGATE (NON-IDENTIFIABLE) STATISTICS ABOUT USERS OF OUR SERVICES TO PROSPECTIVE PARTNERS.
(2) SERVICE PROVIDERS, AGENTS AND THIRD PARTY USES
NEUCOM RETAINS SERVICE PROVIDERS, AGENTS AND SUPPLIERS TO DELIVER PRODUCTS, SERVICES AND OTHER SOLUTIONS. NEUCOM POLICIES REQUIRE THAT SERVICE PROVIDERS, AGENTS AND SUPPLIERS BE REQUIRED BY CONTRACT TO KEEP CONFIDENTIAL THE INFORMATION RECEIVED ON BEHALF OF NEUCOM AND NOT USE OR DISCLOSE IT FOR ANY PURPOSE OTHER THAN TO CARRY OUT THE SERVICES THEY ARE PERFORMING FOR NEUCOM.
(3) FOREIGN SERVICE PROVIDERS, AGENTS AND THIRD PARTIES
SOME OF NEUCOM'S SERVICE PROVIDERS, AGENTS AND SUPPLIERS MAY BE LOCATED OUTSIDE OF THE COUNTRY IN WHICH YOU ARE LOCATED. WHILE PERSONAL INFORMATION AND CLIENT INFORMATION WILL BE SUBJECT TO THE LAWS OF SUCH JURISDICTIONS, NEUCOM'S POLICIES REQUIRE THAT INFORMATION PROCESSED, STORED OR USED BY SERVICE PROVIDERS, AGENTS AND SUPPLIERS ARE ALWAYS SUBJECT TO THE PROTECTIONS DESCRIBED IN THIS PRIVACY POLICY. YOUR PERSONAL INFORMATION AND CLIENT INFORMATION WILL NOT BE DISCLOSED TO THIRD PARTIES EXCEPT WITH YOUR CONSENT OR AS SET OUT IN THIS PRIVACY POLICY.
IF YOU HAVE ANY QUESTIONS ABOUT THE COLLECTION, USE, DISCLOSURE OR STORAGE OF PERSONAL INFORMATION BY SERVICE PROVIDERS OUTSIDE CANADA PLEASE CONTACT NEUCOM'S PRIVACY OFFICER AS DESCRIBED BELOW UNDER "CONTACTING US".
DISCLOSURE OF PERSONAL INFORMATION
NEUCOM WILL NOT SELL, RENT OR LEASE YOUR PERSONAL INFORMATION OR CLIENT INFORMATION TO THIRD PARTIES.
EXCEPT AS DESCRIBED IN THIS PRIVACY POLICY, NEUCOM WILL NOT DISCLOSE THE CLIENT INFORMATION PERSONAL INFORMATION YOU PROVIDE TO NEUCOM TO NON-NEUCOM AFFILIATES, PARTNERS OR THIRD PARTIES WITHOUT YOUR PERMISSION, UNLESS TO: (I) RESPOND TO DULY AUTHORIZED INFORMATION REQUESTS OF LAW ENFORCEMENT AND GOVERNMENTAL AUTHORITIES; (II) COMPLY WITH ANY LAW, REGULATION, SUBPOENA OR COURT ORDER; (III) HELP PREVENT FRAUD OR TO ENFORCE OR PROTECT THE RIGHTS AND PROPERTIES OF NEUCOM OR ITS AFFILIATES; (IV) PROTECT THE PERSONAL SAFETY OF NEUCOM EMPLOYEES, CUSTOMERS OR THIRD PARTIES; (V) ASSIST IN COLLECTING ANY DEBT OWED BY YOU TO NEUCOM; OR (VI) OTHER SUCH DISCLOSURES THAT ARE AUTHORIZED, PERMITTED OR REQUIRED UNDER APPLICABLE LAW.
IF ALL OR PART OF NEUCOM ASSETS ARE SOLD OR FINANCED OR IF NEUCOM WERE TO MERGE WITH ANOTHER COMPANY, CLIENT INFORMATION AND PERSONAL INFORMATION IN POSSESSION OF NEUCOM COULD BE DISCLOSED TO THE LENDER, BUYER OR MERGING ENTITY, PROVIDED SUCH CLIENT INFORMATION AND PERSONAL INFORMATION WERE TO BE USED IN STRICT COMPLIANCE WITH THIS PRIVACY POLICY.3. RETENTION AND SECURITY
NEUCOM RETAINS PERSONAL INFORMATION AND CLIENT INFORMATION FOR AS LONG AS IT IS NECESSARY TO PROCESS RELATED TRANSACTIONS, MAINTAIN APPROPRIATE FINANCIAL AND AUDIT RECORDS, PROTECT NEUCOM'S LEGITIMATE BUSINESS INTERESTS AND FOR AS LONG AS MAY BE REQUIRED BY APPLICABLE LAWS.
ALL PERSONAL INFORMATION AND CLIENT INFORMATION COLLECTED BY NEUCOM IS PROTECTED BY SECURITY MEASURES APPROPRIATE TO THE SENSITIVITY OF THE INFORMATION.4. YOUR CHOICES
HOW NEUCOM OBTAINS YOUR CONSENT
YOU PROVIDE YOUR EXPRESS CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION AND THE USE AND DISCLOSURE OF CLIENT INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY WHEN YOU VOLUNTARILY PROVIDE THE REQUESTED INFORMATION. YOU PROVIDE YOUR IMPLIED CONSENT TO THE USE OF AUTOMATIC DATA COLLECTION TOOLS BY YOUR CONTINUED USE OF THE SITE. IN SOME INSTANCES, THE LAW PERMITS NEUCOM TO COLLECT, USE AND DISCLOSE PERSONAL INFORMATION OBTAINED FROM PUBLIC SOURCES WITHOUT YOUR CONSENT. IF NEUCOM OBTAINS INFORMATION FROM THIRD PARTIES OTHER THAN SUCH PUBLIC SOURCES, NEUCOM REQUIRES THOSE THIRD PARTIES TO CONFIRM THAT THEY HAVE YOUR CONSENT TO DISCLOSE YOUR PERSONAL INFORMATION FOR USE BY NEUCOM.
WITHDRAWAL OF CONSENT
YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT TO THE FURTHER COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AND THE USE AND DISCLOSURE OF CLIENT INFORMATION. IF YOU REQUEST NEUCOM TO DO SO, NEUCOM WILL TAKE STEPS TO DESTROY OR DELETE CLIENT INFORMATION AND PERSONAL INFORMATION THAT YOU HAVE PROVIDED TO US. RESIDUAL CLIENT INFORMATION AND PERSONAL INFORMATION MAY REMAIN IN ARCHIVED RECORDS OR OTHER HISTORICAL RECORDS. IN ADDITION, NEUCOM IS NOT PERMITTED TO DESTROY BUSINESS OR ACCOUNTING RECORDS OF TRANSACTIONS THAT IT IS REQUIRED TO KEEP TO: COMPLY WITH STATUTORY OR OTHER LEGAL OBLIGATIONS AND ASSERT ITS LEGAL RIGHTS. HOWEVER, NEUCOM WILL NOT USE CLIENT INFORMATION OR PERSONAL INFORMATION FOR OTHER COMMERCIAL PURPOSES ONCE YOU WITHDRAW YOUR CONSENT.
THE WITHDRAWAL OF CONSENT TO CERTAIN USES OR DISCLOSURES OF CLIENT INFORMATION AND PERSONAL INFORMATION WILL MEAN THAT NEUCOM IS NO LONGER ABLE TO PROVIDE YOU WITH CERTAIN FEATURES OF THE SITE.
YOU MAY WITHDRAW YOUR CONSENT TO THE USE OF YOUR PERSONAL INFORMATION FOR THE PURPOSE OF SENDING YOU INFORMATION BY E-MAIL BY UNSUBSCRIBING. EACH E-MAIL THAT WE SEND TO YOU WILL PROVIDE YOU WITH THE OPPORTUNITY TO UNSUBSCRIBE.
YOU MAY WITHDRAW YOUR CONSENT TO THE USE OF AUTOMATIC DATA COLLECTION TOOLS BY MANAGING YOUR PRIVACY SETTINGS ON YOUR COMPUTER, YOUR WEB BROWSER AND ANY PRIVACY OR SECURITY SOFTWARE THAT YOU OPERATE ON YOUR COMPUTER. FOR MORE INFORMATION PLEASE SEE THE INSTRUCTIONS THAT ACCOMPANY YOUR COMPUTER, WEB BROWSER AND PRIVACY OR SECURITY SOFTWARE.
IF YOU HAVE ANY QUESTIONS ABOUT THE WITHDRAWAL OF CONSENT TO ONLINE COLLECTION OF PERSONAL INFORMATION, YOU MAY SUBMIT A WRITTEN REQUEST TO NEUCOM'S PRIVACY OFFICER AT THE ADDRESS SET OUT BELOW UNDER "CONTACTING US".
WHEN SUBMITTING A REQUEST, YOU WILL BE ASKED TO PROVIDE SUITABLE IDENTIFICATION OR TO OTHERWISE IDENTIFY YOURSELF.
INDIVIDUAL ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
NEUCOM STRIVES TO KEEP ACCURATE INFORMATION BY USING TECHNOLOGY AND MANAGEMENT PROCESSES AND POLICIES. UPON RECEIPT OF A WRITTEN REQUEST NEUCOM WILL PROVIDE YOU WITH REASONABLE ACCESS TO THE CLIENT INFORMATION AND PERSONAL INFORMATION YOU PROVIDED TO NEUCOM AS WELL AS THE ABILITY TO CORRECT THE INFORMATION, IF NECESSARY.
TO PROTECT YOUR PRIVACY AND SECURITY, NEUCOM WILL ALSO TAKE REASONABLE STEPS TO VERIFY YOUR IDENTITY BEFORE RELEASING ANY INFORMATION TO A REQUESTING PARTY AND BEFORE ANY CORRECTIONS WILL BE MADE. NEUCOM RESERVES THE RIGHT TO REQUEST APPROPRIATE PROOF OF THE REQUESTED CORRECTIONS.
TO ACCESS THE PERSONAL INFORMATION PROVIDED TO NEUCOM AN INDIVIDUAL MUST SUBMIT THEIR REQUEST IN WRITING TO THE ADDRESS SET OUT BELOW UNDER "CONTACTING US".
NEUCOM WILL REFER TO YOU ANY REQUESTS THAT WE MAY RECEIVE FOR ACCESS TO CLIENT INFORMATION HELD BY US ON YOUR BEHALF. WE WILL ALSO ASSIST YOU WHEREVER POSSIBLE IN RESPONDING TO ANY ACCESS REQUESTS YOU MAY RECEIVE.5. CHANGES TO THIS POLICY
NEUCOM MAY REVISE THIS PRIVACY POLICY FROM TIME TO TIME. IF NEUCOM REVISES THIS PRIVACY POLICY, NEUCOM WILL POST A LINK TO THE REVISED PRIVACY POLICY IN ITS ENTIRETY ON GETKASPER.COM TO INCLUDE AN UPDATED REVISION DATE. NEUCOM MAY ALSO NOTIFY YOU BY OTHER MEANS SUCH AS SENDING AN E-MAIL OR POSTING A NOTICE.6. CONTACTING US
NEUCOM WANTS YOUR FEEDBACK. IF YOU HAVE A PRIVACY INQUIRY, COMPLIMENT OR COMPLAINT, YOU MAY CONTACT THE NEUCOM PRIVACY OFFICER BY SUBMITTING A REQUEST ELECTRONICALLY TO:
INFO@GETKASPER.COM

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